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From: Richard Kahn
Sent: 2/15/2017 7:04:23 PM
To: jeffrey E. [jeevacation@gmail.com]
Subject: Fwd: Alert - TIC Form SHC Deadline Approaching
Importance: High
not sure if this applies to Leon
The reporting threshold for Schedule 2 is $200 million in total fair value of all foreign securities owned
by the SHC Reporter and not held with a U.S.-resident custodian
r
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REGULATORY & COMPLIANCE ALERT
FEBRUARY 15, 2017
TIC Form SHC Deadline Approaching - Form Deadline is
March 3, 2017
The U.S. Department of the Treasury recently released a revised Form SHC. Form SHC, which is part of
the Treasury International Capital ("TIC") data reporting system, is the mandatory five-year benchmark
survey of the ownership of foreign securities by U.S. residents. Absent an announcement of a delay
from the Trump administration, the report is due to the Federal Reserve Board of NY ("FRBNY") by March
3, 2017 for data reportable as of December 31, 2016.
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All U.S. resident custodians and end-investors with holdings of foreign portfolio securities above the
reporting thresholds must report. In addition, all U.S.-resident custodians and end-investors that are
notified by the FRBNY are required to file a report.
The reporting threshold for Schedule 2 is $200 million in total fair value of all foreign securities owned
by the SHC Reporter and not held with a U.S.-resident custodian. The reporting threshold for Schedule
3 is $200 million in total fair value of foreign securities held with any one unaffiliated U.S.-resident
custodian that is not a central securities depository.
Custodians are all organizations that hold securities in safekeeping for other organizations. Most U.S.-
resident custodians also invest in foreign securities for their own account. U.S.-resident custodians
should report both the foreign portfolio securities held in safekeeping for other U.S. residents and their
own foreign portfolio securities.
End-investors are U.S.-resident organizations that invest in foreign securities for their own portfolios or
invest on behalf of others, such as investment managers/fund sponsors. This includes securities that are
held-for-trading, available-for-sale, or held-to-maturity. U.S.-resident end-investors include, but are not
limited to:
• Financial and non-financial organizations
• Managers of private and public pension funds
• Managers/sponsors of funds, country funds, unit-investment funds, exchange-traded funds,
collective-investment trusts, hedge funds or any other similarly pooled, commingled funds. Also
managers/sponsors of private equity companies, venture capital companies, hedge funds and other
private investment vehicles
• Insurance companies
• Foundations
• Institutions of higher learning
• Trusts and estates
• Funds and similar entities that own shares or units of, or other portfolio equity interests in,
a foreign related or non-related entity
Form SHC is comprised of three schedules:
Schedule 1 - Must be filed by all entities thati) receive a copy of the SHC forms and instructions
from the FRBNY, or 2) are notified by the FRBNY that they are required to file the SHC report.
Schedule 1 requests information that identifies the reporter. It also provides contact
information, indicates the reporting status, and summarizes the data, if any, reported on
Schedule 2 and/or Schedule 3.
Schedule 2 - Used to report detailed information on foreign securities owned by U.S.-resident
investors (1) that the reporter safe-keeps for itself or for its U.S.-resident clients or (2) for which
the reporter directly employs foreign-resident sub-custodians or U.S.-resident or foreign-
resident central securities depositories (CSDs) to manage the safekeeping of those securities
(Foreign securities in safekeeping with U.S.-resident CSDs are reportable on Schedule 2.) or (3)
that are instruments of the type that there is no U.S. custodian to manage the safekeeping of
those securities.
Schedule 3 - Used to report summary amounts for all foreign securities entrusted to the
safekeeping of a U.S.-resident custodian, excluding those entrusted to a U.S. - resident CSD.
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Completed reports may be submitted to the FRBNY on paper or electronically through the Federal
Reserve Reporting Central System. Additional information and a copy of the Form SCH are available
here.
If you have any questions regarding this Alert, please contact Dan Viola at dviola@sglawyers.com.
Sadis & Goldberg LLP
Please feel free to discuss any aspect of this Alert with your regular Sadis & Goldberg contact
whose names and contact information are provided below.
Alex Gelinas, 212.573.8159, agelinas@sglawyers.com
Daniel G. Viola, 212.573.8038, dviola@sglawyers.com
Danielle Epstein-Day, 212.573.8416, depstein@sglawyers.com
Douglas Hirsch, 212.573.6670, dhirsch@sglawyers.com
Erika Winkler, 212.573.8022, ewinkler@sglawyers.com
Greg Hartmann, 212.573.8030, ghartmann@sglawyers.com
Jeffrey Goldberg, 212.573.6666, jgoldberg@sglawyers.com
Jennifer Rossan, 212.573.8783, jrossan@sglawyers.com
John Araneo, 212.573.8158, jaraneo@sglawyers.com
Mitchell Taras, 212.5738417, mtaras@sglawyers.com
Paul Fasciano, 212.573.8023, pfasciano@sglawyers.com
Ron S. Geffner, 212.573.6660, rgeffner@sglawyers.com
Sam Lieberman, 212.573.8164, slieberman@sglawyers.com
Steven Etkind, 212.573.8412, setkind@sglawyers.com
Steven Huttler, 212.573.8424, shuttler@sglawyers.com
Yehuda Braunstein, 212.573.8029, ybraunstein@sglawyers.com
Yelena Maltser, 212.573.8429, ymaltser@sglawyers.com
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